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Go to T.C. Memo. 2005-221 (not yet in the library — opens the official source)
73 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 90 FR 3667 — Prohibited Transaction Exemption (PTE) 2002-51 To Permit Certain Transactions Identified in the Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025related by meaning
    e use of the SCC and suggested that the Department should allow self-correctors to choose whether (a) to provide notice to interested persons (but not to EBSA) or (b) make the plan contribution. After considering these comments, the Department has not made this change. Self-correctors have a streamlined procedure for s…
  2. Notice 2006-79 — This notice sets forth additional transition relief under section 409A. The notice generally extends through December 31, 2007, the transition relief that prev…
    IRCNoticesOct 23, 2006
    Notice 2005-1, Q&A-21 provided relief with respect to certain initial deferral elections, generally providing that certain requirements would not be applicable to elections made on or before March 15, 2005. One of the conditions of the requirement was that the plan be amended to comply with the requirements of section …
  3. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…
  4. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    …on cash payment to petitioner’s IRA and a $14 million promissory note payable to his IRA. In August 2005 TEOHC paid the promissory note in full. For the 2004 taxable year petitioner alleges that TEOHC issued him a Form 1099 – R, Distributions From Pensions, Annuities, Retirement or Profit - Sharing Plans, IRAs, Insuran…
  5. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  6. 87 FR 70753 — Prohibited Transaction Exemption (PTE) 2002-51 To Permit Certain Transactions Identified in the Voluntary Fiduciary Correction Program
    ERISAProposed Rules (FR)Proposed Nov 21, 2022related by meaning
    he Department no longer believes that posting the notification is reasonably calculated to ensure that interested persons actually receive the notice. The Department has reviewed several notices to interested persons submitted to the applicable Regional Offices and found that some of them do not meet the applicable req…
  7. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026related by meaning
    B. 2026-01 143 2026-4 2026-01 I.R.B. 2026-01 160 2026-5 2026-01 I.R.B. 2026-01 258 2026-6 2026-02 I.R.B. 2026-02 314 2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380 2026-9 2026-04 I.R.B. 2026-04 393 2026-10 2026-04 I.R.B. 2026-04 394 2026-12 2026-07 I.R.B. 2026-07 535 2026-13 2026-09 I.R.B. 2026-09 …
  8. Rev. Rul. 2004-104 — 2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in …
    IRCRevenue RulingsNov 15, 2004
    EMPLOYEE PLANS Rev. Rul. 2004-104 Rev. Rul. 2004-104 2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in determining contributions to defined benefit plans and permitted disparity. Notice 2004-72 Notice 2004-72 20…
  9. T.D. 9072 — Final regulations under section 414(v) of the Code provide guidance on the requirements for retirement plans providing for catch-up contributions to individual…
    IRCTreasury DecisionsSep 15, 2003
    …plan year that is not the calendar year. For example, in a plan with a plan year ending on June 30, 2005, elective deferrals in excess of the employer-provided limit or the ADP limit for the plan year ending June 30, 2005, would be treated as catch-up contributions as of the last day of the plan year, up to the catch-u…
  10. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8 (2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on the date which is 60 days after the later of . . . [the] earliest incident date . . …
  11. Treas. Reg. § 1.409(p)-1T(h) — Prohibited allocations of securities in an S corporation (temporary).
    IRCRegulationsMay 18, 2016
    icequity shares on determination date January 1, 2005 A grant is made on January 1, 2005 with a present value of $1,000. An additional grant of nonqualified deferred compensation with a present value of $775 is made on March 1, 2005 $10 per share 100 100 January 1, 2006 An additional grant is made on December 31, 2005 …
  12. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    … years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-277 UNITED STATES TAX COURT MARGARET M. MERKER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26855-95. Filed June 18, 1997. Margaret M. Merker, pro se. Marjory A. Gilbert , for respon…
  13. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 - II. Administrative Costs The administrative costs at issue are costs that petitioner incurred from the . time respondent issued the notice of deficiency up to the …
  14. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
  15. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    all of the contentions and arguments of the parties that are not discussed herein, and we conclude that they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits : "According to Section 6673, this court may penalize Petitioner up to $25,000 for failure to complete the admin…
  16. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006
    … the group use a 52-53 week taxable year). SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES Rev. Proc. 2005-3, 2005-1 C.B. 118, Rev. Proc. 2005-61, 2005-37 I.R.B. 507, and Rev. Proc. 2005-68, 2005-41 I.R.B. 694, are superseded. SECTION 8. EFFECTIVE DATE This revenue procedure is effective January 3, 2006. SECTION 9. PAPER…
  17. PLR 199941054 — Non-Exempt Funds or Plans
    IRCPrivate Letter RulingsOct 15, 1999related by meaning
    …BEO:4 WTA-N-115872-99 UILC: 404.04-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE CHIEF COUNSEL ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizations) CC:EBEO SUBJECT: Film Participations and Section 404 On July 16, 1999, we issued Chief Counsel Advice (CCA)(199936044) to you on …
  18. Rev. Proc. 2006-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 3, 2006
    or subsequent years, in accordance with the rules set forth in Rev. Proc. 2005-66. Other Guidance .03 Other guidance affecting this revenue procedure: Rev. Proc. 2005-16, 2005-10 I.R.B. 674, describes the procedures for the “pre-approval” of plans under the master and prototype (M&P) program and the volume submitter (V…
  19. T.C. Summary Opinion 2005-78 — Hossam Helmy El-Bibany & Salma Hassan Kandil v. Commissioner
    IRCCourt RulingsJun 8, 2005related by meaning
    … and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Summary Opinion 2005-78 UNITED STATES TAX COURT HOSSAM HELMY EL-BIBANY AND SALMA HASSAN KANDIL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9960-04S. Filed June 8, 2005. Hossam Helmy El-Bibany and Salma Hassa…
  20. T.C. Memo. 2011-83 — Bruce A. & Carol Anfinson Brown v. Commissioner
    IRCCourt RulingsApr 12, 2011
    to exceed the policy's cash value, and Northwestern terminated the policy on | January 6, 2005. On February 16, 2005, Northwestern restored the policy because Mr. Brown made a $559 "minimum interest payment" of which $428.04 went to interest and $130.96 went to principal. On March 21, 2005, Mr. Brown made a final cash …